This statement has been published pursuant to section 54 of the UK Modern Slavery Act 2015, and applies to Mindray (UK) Limited, Mindray’s ultimate parent company, Shenzhen Mindray Bio-Medical Electronics Co., Ltd. and its subsidiaries (“Mindray Group”). It sets out the steps taken by the Mindray Group during the financial year ended 31 December 2024 to address modern slavery and human trafficking in its business and supply chains. Any reference to “Mindray” herein refers to the Mindray Group as described in this paragraph.

Mindray is committed to fully complying with all applicable labour and employment laws, rules and regulations and working to mitigate the risk of human trafficking in our business and supply chains. This Statement is consistent with the Mindray Code of Business Conduct and Ethics and Mindray core values of treating all people with respect and dignity.

The Modern Slavery Act 2015 requires commercial organisations with an annual turnover exceeding £36m and operating in the UK to produce an annual transparency statement. Mindray UK Ltd is publishing this annual transparency statement on a voluntary basis, regardless of its financial performance in the relevant financial year, to show its commitment to combatting any form of slavery and human trafficking.

Introduction

Mindray takes its responsibility as a positive global corporate citizen to heart. Mindray is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain, and imposes the same high standards on its suppliers. At Mindray we are committed to improving our practices to combat slavery and human trafficking.

Mindray was founded on the belief that every life is valuable. As expensive and complex technology still remains out of reach for the majority of people, we are striving to improve healthcare by developing and sharing medical technologies with the world. In doing this we can provide better care for more people, not just with our customers in mind but with humanity in mind. Mindray actively participates in Corporate Social Responsibility (CSR) and Environmental, Social, and Governance (ESG) projects, and is committed to collaborating with Non-Governmental Organizations (NGOs) and industry partners to jointly promote the identification and mitigation of modern slavery risks. We are exploring partnerships with international human rights organizations to enhance employee rights protection and improve supply chain transparency. Mindray also engages in industry alliances to share best practices and promote ethical procurement standards in the global healthcare industry.

Mindray’s Business

Mindray is one of the leading global providers of medical devices and solutions. Headquartered in Shenzhen, P.R.China, Mindray has 62 overseas subsidiaries in approximately 40 countries and 26 subsidiaries and approximately 30 branches in the territory of P.R.China (excluding Hongkong, Taiwan and Macau). To find out more about the nature of our business, please click here.

Our Supply Chains

In order to produce and distribute our medical devices and solutions, we work with a range of suppliers involved in the procurement of raw materials, services, logistics, as well as product transportation to our warehouses, agents, distributors and end customers.

Our suppliers come from all over the world. We work mainly with Chinese suppliers, but also with suppliers from the United States, Germany, Sweden, Finland, the United Kingdom, Japan and other countries.

Mindray requires its suppliers to respect and not to infringe in any way internationally-recognized rights of employees, and also requires its suppliers to comply with all applicable laws and regulations to offer fair working conditions and implement health and safety management processes for all aspects of their business activities.

Based on the long-life cycle of Mindray's products, we expect to maintain long-term cooperative relationships with suppliers. More than 45% of suppliers have cooperated with Mindray for more than 10 years. In the process of supplier introduction and cooperation, suppliers are continuously reviewed and trained to achieve the goal of long-term development in harmony with each other.

Our Policies

Mindray has recently updated its Group Code of Business Conduct and Ethics to better emphasise its commitment to combatting the risk of modern slavery in our operations and supply chain; in this respect, we have also implemented our Combating Trafficking in Persons Policy, which applies to the Mindray Group except Mindray DS USA Inc., and our Mindray DS Combating Trafficking in Persons Policy, specifically tailored and applicable to our US legal entity, Mindray DS USA Inc.

Due Diligence

Due diligence processes for slavery and human trafficking

As part of our initiative to identify and mitigate risks, we have procedures in place to:

• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains.

Mindray uses multiple methods to identify third parties risks, including Refinitiv Due Diligence data and analytics services and Lexis Nexis Diligence platform, web-based interfaces featuring global news, business, legal, public records and regulatory content, to conduct due diligence on third parties including but not limited to service suppliers. Mindray third parties management system has also been enhanced by the use of “Due Diligence Questionnaire for Business Associates” (e.g. distributors) that, among other things, addresses specifically Modern Slavery and Human Trafficking risks.

On-boarding, auditing and appraising our suppliers

New suppliers are subject to due diligence checks in the form of: (a) a due diligence questionnaire including responsible business practices, and (b) an on-site audits.

As part of the on-boarding process Mindray has also introduced a “Supplier Compliance Statement” that all suppliers must execute before performing a supply contract. The statement in question covers, among other things, Modern Slavery and Human Trafficking risks. Moreover, new contents related to Modern Slavery and Human Trafficking risks have been added to the ongoing "Mindray Supplier Review Assessment Form". Mindray conveys basic employee rights through supplier training and compliance documents, ensuring Tier 1 suppliers employees understand their employment rights. We also provide anonymous grievance mechanisms at Tier 1 level and plan to gradually cover Tier 2 and Tier 3 suppliers.

The on-site audit is managed by the Procurement Team, who will conduct the audit, and record the audit findings according to Mindray’s scoring standards. Conducting an on-site audit is Mindray’s standard approach, however at times Mindray’s Procurement Team may decide not to conduct an on-site audit based on the supplier’s risk-category and other factors.

The on-site audit includes questions to evaluate to what extent the supplier protects employees, including: (i) safety measures and protective equipment, (ii) reporting and records of any incidents or injuries, (iii) prohibition of child labour and compliance with local labour law, (iv) a working environment free from discrimination, (v) communication of employees’ rights, (vi) emergency planning, (vii) environmental management systems, (viii) compliance with environmental laws, (ix) waste management, (x) actions to monitor and minimize negative environmental impacts. Suppliers whose audit results are satisfactory can be introduced as qualified suppliers; whilst suppliers whose audit results are conditional upon the implementation of a rectification plan, will need to demonstrate compliance before being approved. The audit team tracks suppliers’ rectification efforts through an "Improvement Evaluation Form".

Suppliers that are already part of Mindray’s supply chain may be subjected to annual review from a responsible business perspective depending on their performance, risk profile, and importance for the business. The review process monitors, among other factors, the type of supplier, suppliers’ performance in the previous year, and compliance with Mindray’s responsible business requirements, which include prohibition on modern slavery, human trafficking, discrimination, harassment, sexual abuse and child labour. The above actions allows Mindray to have key performance indicators to measure progress in tackling modern slavery in its supply chain.

Supply chain management, monitoring and compliance

We have zero tolerance to slavery and human trafficking. We have a procedure in place to monitor compliance and initiate remediation action. If there is a risk of non-compliance with any of Mindray’s values, which include a prohibition on slavery and human trafficking, we issue a “non-conformity improvement evaluation form” to the supplier. Upon receipt of such form, the supplier has to initiate remediation action. Mindray will then check the effectiveness of the remediation, through a site visit if necessary. If the supplier fails to make effective remediation within the agreed period, Mindray will cease to conduct business with that supplier.

Mindray has implemented a training programme on Modern Slavery policies to Supply Chain employees and suppliers.

Mindray hereby declares that no incidents of modern slavery have been recorded or discovered within our organization or supply chain in the past 12 months.

Training and Further Steps Taken

Communication

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we regularly share our policies internally with our employees along with this statement.

Mindray (UK) has rolled out a mandatory training for its employees that helps understand how to identify and report signs of Modern Slavery and prevent modern slavery from happening.

Further Steps

In the last 12 months, as part of our commitment to combatting the risk of modern slavery in our operations and supply chain, Mindray has undertaken the following steps:

A training campaign has been rolled out to explain the recently-updated “Code of Business Conduct and Ethics” and better emphasise our commitment to doing business with integrity. The new Code of Business Conduct and Ethics, among other things, reinforces our commitment to combatting the risk of Modern Slavery and Human Trafficking.

Mindray UK has implemented a monitoring system to control completion rate of the UK mandatory training on modern slavery and human trafficking risks.

Mindray (UK) mandatory training helps understand how to identify and report signs of Modern Slavery and prevent modern slavery from happening. The training also:

• Helps understand the scale of Modern Slavery;
• Describes employees’ responsibilities under the Modern Slavery Act 2015;
• Explains what Modern Slavery is;
• Explain how to spot the signs of Modern Slavery;
• and how to report Modern Slavery.

Mindray UK has recently updated its Terms and Conditions of Sale and, among other things, has adopted specific Modern Slavery and Huan Trafficking clauses. As result, customers are required to comply with the Modern Slavery Act 2015 and to notify Mindray UK immediately in writing if they become aware or have reason to believe that they, or any of their officers, employees, agents or subcontractors have breached or potentially breached any Modern Slavery related obligations. Any breach of such obligations is deemed a material breach of contract.

Mindray, as a global medical solutions provider, has recently achieved an outstanding AA rating for its Environmental, Social and Governance (ESG) practices from Morgan Stanley Capital International (MSCI), a renowned international rating agency. This rating is the highest in the A-share market, signifying Mindray's impressive advancement towards being a leader in ESG management across the globe and specifically in the medical device industry.

According to MSCI's latest ESG rating report on Mindray, Mindray’s sustainable development practices in the social and governance areas have promoted the rating upgrade. The company's practices in human resources management, product quality assurance, and business ethics are leading the industry.

Mindray places employees at the centre of the sustainable development strategy. Mindray has established 62 overseas subsidiary companies in 26 countries that employ 100% local employees in 29 countries. Mindray prioritizes equality in the workplace, providing equal and broad development opportunities for every individual. Mindray factually respects cultural differences existing between different countries and regions while avoiding discrimination or prejudice based on age, gender, nationality, race, skin colour, or religious beliefs.

Regarding its corporate governance and business ethics, MSCI affirms the company's protection of whistleblowers and its regular compliance audits on anti-corruption practices. Mindray advocates and practices complete honesty and trustworthiness in all business operations, strictly complying with any laws and regulations related to anti-corruption, preventing conflicts of interest, anti-fraud, anti-monopoly, and anti-unfair competition. The company conducts regular ethics audits and encourages all employees to study relevant system rules and regulations. Furthermore, Mindray invites all stakeholders, including employees, suppliers, and others, to report any illegal or disciplinary action related to the company via various channels - publicly or anonymously. The company firmly protects the rights and interests of whistleblowers and ensures that they are not subjected to any unfair or retaliatory measures.

Mindray was recently awarded the Silver Medal in the EcoVadis Sustainability Assessment, ranking among the top 25% of all evaluated companies. This recognition reflects Mindray outstanding performance within the global medical device industry and signifies its progression towards becoming a leader in ESG (Environmental, Social, and Governance) governance in the healthcare sector.

We believe the above mentioned achievements are a recognition for the efforts Mindray is putting to ensure the highest ethical standards are achieved by the organisation, including standards and regulations around Modern Slavery and Human Trafficking risks.

Approvals

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Mindray Group’s modern slavery and human trafficking statement for the financial year ending 31 December 2024. It has been approved by the board of directors of Mindray (UK) Limited with respect to the financial year ending on 31 December 2024 and is signed on behalf of the board by its General Manager.

General Manager

Paul Bailey